Privacy Policy

1. Controller

The data controller responsible for the processing of personal data on this website is:

2. Legal Basis

This Privacy Policy is issued in accordance with the Swiss Federal Act on Data Protection (nFADP/nDSG) which came into force on 1 September 2023, and, where applicable, the EU General Data Protection Regulation (GDPR). We process personal data based on: consent, contractual necessity, legal obligations, and legitimate interests.

3. Data We Collect

We collect the following personal data:

4. Data Processors

We use the following third-party services to process data on our behalf:

All US-based processors operate under Standard Contractual Clauses (SCCs) or equivalent data protection agreements ensuring adequate protection of personal data.

5. Cookies

We use essential cookies required for the website to function. Analytics cookies are only used with your explicit consent (see our cookie banner). You can manage your cookie preferences at any time by clearing your browser data. We do not use advertising or tracking cookies.

6. Data Retention

Personal data is retained for the duration of the contractual relationship plus the legally required retention period (10 years for financial records under Swiss law). Swim progress reports and skill assessments are retained for 3 years after the last class attended. You may request earlier deletion of non-legally required data.

7. Your Rights

Under Swiss data protection law (nDSG), you have the right to:

• Access — request a copy of your personal data
• Rectification — correct inaccurate data
• Deletion — request deletion of data (subject to legal retention requirements)
• Portability — receive your data in a structured, machine-readable format
• Object — object to processing based on legitimate interests
• Withdraw consent — withdraw consent at any time without affecting prior processing

To exercise any of these rights, contact us at luna@aquaswim.ch. We will respond within 30 days.

8. Data of Minors

As a swim school, we process data of children (swimmers). This data is provided by the parent or legal guardian and is processed solely for the purpose of delivering swim classes and tracking progress. We do not collect data directly from children. Parents may exercise data rights on behalf of their children.

9. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction. This includes encryption of data in transit (TLS/SSL), secure payment processing via Stripe (PCI DSS compliant), and access controls for staff and coaches.

10. International Transfers

Some of our data processors are based outside Switzerland (see Section 4). Where data is transferred to countries without an adequate level of data protection, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the Swiss Federal Data Protection and Information Commissioner (FDPIC).

11. Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC):

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically. Continued use of our services after changes constitutes acceptance of the revised policy.